1. Statement of Intent
klyr has a zero-tolerance approach to bribery and corruption. We are committed to conducting all business honestly, transparently, and with integrity. We comply with the UK Bribery Act 2010 and expect the same standards from everyone we work with.
2. Scope
This policy applies to:
- All employees, directors and officers
- Freelancers, contractors and temporary staff
- Third-party partners, suppliers and representatives acting on klyr’s behalf
Compliance with this policy is a condition of working with us.
3. What Constitutes Bribery
Bribery is the offering, giving, requesting or receiving of:
- Cash payments
- Gifts, hospitality or services
- Favourable treatment
- Any benefit intended to improperly influence a decision or secure an advantage
Bribery can be direct or indirect, including through a third party.
4. Prohibited Conduct
The following are strictly prohibited:
- Offering, promising or giving a bribe
- Requesting, agreeing to receive, or accepting a bribe
- Facilitation payments or unofficial “speeding up” fees
- Kickbacks, referral payments or undisclosed commissions
- Improper influence during procurement or tender processes
5. Gifts, Hospitality & Entertainment
klyr recognises that modest hospitality can form part of business relationships. However:
- Gifts or hospitality must never be offered or accepted to influence a decision
- Anything more than modest and occasional must be declared to klyr leadership
- Cash or cash-equivalent gifts (vouchers, prepaid cards, etc.) are never permitted
- Staff must refuse or report any offer that feels inappropriate, excessive or timed to influence a business decision
6. Conflicts of Interest
Staff and contractors must disclose:
- Personal relationships with suppliers or clients
- Financial interests in companies bidding for work
- Situations where impartiality could reasonably be questioned
klyr may require individuals to step back from specific decisions.
7. Third-Party Risk
We expect suppliers, production partners and contractors to uphold equivalent anti-bribery standards.
Due diligence may be carried out before appointing high-risk suppliers or partners.
8. Reporting & Whistleblowing
Concerns about potential bribery, unethical conduct or suspicious activity must be reported to klyr leadership immediately. Reports will be treated confidentially and without retaliation.
9. Record-Keeping
klyr will maintain accurate records related to:
- Gifts and hospitality
- Third-party agreements
- Production costs and expenses
- Procurement decisions
Records must never be altered or falsified.
10. Enforcement
Breaches of this policy may result in:
- Disciplinary action
- Termination of employment or contract
- Removal from approved supplier lists
- Reporting to law enforcement or regulatory agencies
klyr reserves the right to refuse to work with any individual or organisation that does not adhere to this policy.
Please flag any concerns of potential breaches to concerns@weareklyr.com
